Toby Potter Chair of IMAP today wrote an article in the current edition of Financial Standard.
The article, titled "Climate Change in the Managed Accounts Biosphere" draws parallels between manmade environmental change and its impact on the natural environment.
Referring to ASIC and its update to the regulations, Toby ponders over which financial services species are likely to be environmentally favoured and which may be treated like an introduced pest, namely the Limited MDA – a species introduced in 2004 is to be eradicated by October 2018.
The banning order is going to force a bit of genetic modification on the AFSLs and advisers who have comfortably occupied this niche for the past decade or so. Having had adaptation forced on them, these AFSLs and advisers are most likely to think about evolving into:
• An MDA Provider, or
• An external adviser to someone else’s MDA service , or
• An adviser on standard platform SMAs, or
• An investment manager on a platform that will offer their portfolios as customised SMAs
There are positive aspects of the regulations and ASICs new MDA regulations are strongly supportive of diversity of approach to the provision of MDA services. ASIC has recognised MDA services that are, for example :
• Operated on a regulated platform
• And / or with an external adviser who is responsible for an annual review
• And / or with assets held by a custodian or in client own name
• And / or with external, outsourced administration
However, ASIC spoke at a recent briefing organised by IMAP to provide the background to their thinking about the changes to the regulations. it was made clear that when an AFSL applies to be an MDA provider, whatever variety of advice, administration, custody, investment management they propose to undertake, ASIC are intending to apply a common standard of expertise, resources and experience.
IMAP is preparing a strategic workshop to help AFSLs pick their way through the options because the most obvious – becoming an MDA provider – is likely to come with a compliance burden that is both onerous and expensive. Info on this workshop will be released shortly.
Click here to read the full article in this week's Financial Standard